The purpose of this privacy policy (hereinafter the "Policy") is to inform visitors or users (hereinafter the "User") of the website www.sarpi.veolia. com (hereinafter the "Site") of the terms and conditions for the protection of their personal data in accordance with Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms as amended by the Law of June 20, 2018, the implementing Decree No. 2019-536 of May 29, 2019 and Regulation No. 2016-679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter collectively the "Regulations").
The publisher of the Site is VEOLIA ENVIRONNEMENT SA, a company registered with the Nanterre Trade and Companies Register under no. 403 210 032, whose registered office is located at 21 rue de la Boétie, 78008 Paris (hereinafter "the Publisher" or "Veolia").
The terms and conditions for processing data collected through contact form(s) are set out in the Information Notice for the form(s).
The Policy may be modified at any time by Veolia, in particular to comply with any regulatory, legal, editorial or technical developments.
This Privacy Policy is an integral part of the General Terms and Conditions of Use of the Site.
The methods of collecting and processing information collected by means of cookies are set out in the following page : https://www.sarpi.veolia.com/en/information-about-cookies
IDENTIFICATION OF THE DATA CONTROLLER
The controller of the User's personal data is, as the case may be, the following entity :
- Veolia Environnement SA ;
- SARP Industries, SA (hereinafter "SARPI");
- The SARP Industries entity responsible for processing the User's request or answering his question, depending on the subject of the request entered in the contact form.
DESCRIPTION OF THE PROCESSING
Within the framework of the operation of the Site, the Publisher may collect and process personal data in order to allow the User to access the features and services offered by the Site (hereinafter the "Services").
1) What are the categories of data collected?
- Contact data: refers to the mandatory data that the User fills in when filling in the contact form(s), namely: surname, first name, email address, company name, telephone number, address, postcode, town, country of residence.
- Data voluntarily published by the User: refers to the personal information that the User voluntarily communicates to the Editor by filling in the free text zones provided for this purpose in the contact form(s), namely "Subject of the request" and "Message". The Publisher strongly recommends to the User to avoid any communication of personal data via these text boxes or in any case to limit this communication to what is strictly necessary to process the User's request (hereafter "Published Data").
All such data is hereinafter collectively referred to as "Data".
2) Why does the Publisher collect the User's Data?
The Data is collected through the contact form in order to answer the User's questions concerning the following main topics
- Collecting information requests from target audiences (customers, stakeholders, candidates)
- To process the User's request for information or question and to communicate effectively with the User in the following areas: human resources, business and communication
- To send communications to the User in relation to the main interests they have previously expressed.
The mandatory fields in the contact form are identified by an asterisk. If you do not fill in these mandatory fields, SARPI will not be able to respond to your request.
3) What are the legal bases for the processing of User Data?
Data processing is only lawful if it is based on one of the legal bases defined by the Regulations. In the context of the operation of the Site, the processing is based on the following legal grounds:
- If the User is a professional prospect wishing to receive information or make requests about the activities and services offered by SARPI in relation to the specific needs he or she has previously expressed, or if the User is already a client of SARPI: SARPI's legitimate interest.
- If the User is a prospect (professional), the Publisher collects his consent by means of a checkbox before sending any global information via commercial communications.
- If the User is a candidate (or potential candidate): SARPI's legitimate interest is to respond to the candidate's/potential candidate's request.
- If the User is a supplier: the contract or the execution of pre-contractual measures taken at the request of the data subject.
- If the User is a stakeholder: consent is collected by means of a checkbox.
4) Recipients of the Data collected
The Data collected through the contact form is intended for the internal departments of the entity responsible for processing and responding to the User's request.
This may include, depending on the case, the "Sales", "Human Resources" or "Communication" departments.
Internal recipients may also be Veolia Group entities located in the European Union (EU) or outside the EU, it being understood that any transfer of Data outside the EU will be carried out under the conditions of the article "Transfer of Data outside the European Union" below.
Each receiving subsidiary may, as the case may be, be a subcontractor or a processor of the Data provided.
The Data may also be transferred/used by third parties under the following conditions:
- Data transferred to public authorities and/or bodies
In accordance with the Regulations in force, the Data may be transferred to the competent authorities upon request, and in particular to public bodies, exclusively to meet legal obligations, judicial officers, ministerial officers and bodies responsible for collecting debts, as well as in the case of the search for the authors of offences committed on the Internet.
- Data communicated to third parties
The Data may be communicated or made accessible to the Publisher's subcontractors, suppliers, and third-party service providers (such as the Site host, Veolia's IT and/or technical service providers).
- Social networks
Users may share pages of interest on social networks by clicking on the share buttons.
The collection of information by the sharing buttons of social networks is subject to the privacy policies of these third parties. We invite you to read the policies of these social networks to know how your personal data is used.
EXERCISE OF THE USER'S RIGHTS
In accordance with the Regulations, every natural person User has the right to access, rectify, delete, limit and port his or her Data.
The User also has the right to define general and specific directives defining the way in which he/she intends his/her rights to be exercised, after his/her death.
For all processing carried out within the framework of the Site and only within this framework, regardless of the Entity responsible for processing, the User may exercise his rights
- by writing to [email protected]
or
- by post to : Mr. Data Protection Officer, Sarp Industries, 427 route du Hazay, 78520 Limay
by sending proof of identity or any other official document.
In the event of any difficulty concerning the management of his personal Data by the Publisher, the User may contact the Data Protection Officer of Sarp Industries (e-mail address: [email protected]. If the response from the DPO is not satisfactory, the User may submit a complaint to the competent protection authority (CNIL - 3, place de Fontenoy - TSA 80715 - 75334 Paris Cedex 07).
The Publisher reminds that the User may, for legitimate reasons, oppose the processing of Data concerning him/her.
When the processing is based on consent, the User may withdraw his consent at any time by sending an e-mail to [email protected].
It is specified that if the User exercises some of his rights above, the Publisher may be unable to perform the actions necessary to achieve the purposes described above, or the User may not be able to use all or part of the Services.
The Publisher has the obligation to keep the Data collected from the Users up to date. It is therefore recommended that the User inform the Publisher of any changes concerning him/her by sending an e-mail to the following address: [email protected].
DURATION OF THE RETENTION AND ARCHIVING OF DATA
User Data will not be retained beyond the period strictly necessary for the purposes set out herein and in accordance with the Regulations.
In this respect :
|
Data processed |
Data retention periods |
|
To respond to requests for commercial information |
For the entire period necessary for processing or for 5 years after the end of the active contractual relationship, unless the User has exercised his/her right to object, his/her right to withdraw or his/her right to erasure (as the case may be); if necessary, they may be kept in an intermediate archive for 5 years after the last request. |
|
For contact requests concerning the human resources department |
For the duration of the processing or for the duration of the active contractual relationship, unless the User has exercised his/her right to object, his/her right to withdraw or his/her right to erasure (as the case may be); they may, if necessary, be kept in an intermediate archive for five years at the end of the contractual relationshi |
|
To respond to general information requests |
For a period of 18 months from the last contact, unless this contact has given rise to a contractual relationship, in which case the data will be kept for the period specified for each type of data processed, unless the User has exercised his/her right to object, his/her right to withdraw or his/her right to erasure (as applicable) |
The Data is kept in intermediate storage to enable SARPI to defend itself in any legal proceedings or for the prevention and detection of criminal offences, with the aim of making the Data available to the judicial authorities.
At the end of the intermediate archiving period, the User Data will be definitively deleted.
In addition, the Publisher may store Data in a permanently anonymised manner, for the purpose of producing statistical studies. In no case these studies allow the identification of the Users, and only concern the trends resulting from their aggregated Data.
SECURITY
The Publisher takes appropriate technical and organizational measures to ensure the security of the Data and to prevent unauthorized access to or disclosure of the User Data. However, the Publisher cannot guarantee the elimination of any risk of misappropriation, alteration, illicit reproduction or misuse of the Data.
The database created when a User sends a request through the contact form is strictly confidential. Veolia undertakes to take all useful precautions, organisational and technical measures appropriate to preserve the security, integrity and confidentiality of the Data and, in particular, to prevent it from being distorted, damaged or accessed by unauthorised third parties.
TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION
If User Data is transferred to a subsidiary of Groupe Veolia or to a third party located outside the European Union, Sarpi ensures that the recipient country has been granted an adequacy decision by the European Commission. If this is not the case, Sarpi undertakes to use the appropriate legal instruments to govern the transfer, including the European Commission's Standard Model Contractual Clauses.
If the User wishes to obtain more information about how Sarpi protects its Data or wishes to obtain a copy of the legal instruments used, the User may request this information from [email protected].